Other types of information we collect:

1. Vehicle information (including registration number, chassis series, service reminders, mileage and warranty repair information;
2. The date and time you used our services;
3. Cookie, pixel or beacon information;
4. The address of the website from which you accessed our website;
5. Details of any transaction between you and us;
6. If you engage with us in a business context, we may collect your job title, company contact details (including email addresses), fleet size and company details;
7. Voice recordings of calls you make to our customer service center;
8. "Live chat" recordings;
9. Within your Personal page on the online sales platform with the desired product, delivery address, billing details, payment method data as well as card or bank account details.
10. Any information from correspondence you send to us.

We also offer the possibility to register on the THT platform (ex.EVW) through your Facebook, Google, Youtube or any social media account. If you choose one of these options, you will be directed to a page managed by the operators of the social media site, where they will inform you about the transfer of your data to THT (ex.EVW). You can consult the privacy policies of the social media sites by accessing the links on the websites of the owning companies.

We also collect data from public sources

Please note that we also collect data from (public) sources such as credit agencies, chambers of commerce, etc.

How long do we keep your personal data?

We store your personal data for as long as necessary for the purposes for which we collected it, for the period permitted by law and defined by our internal data retention policies.

Other data processing purposes and how we may use this information

THT will use the information for the following purposes:

• To be able to process your request in the event of a service order, sale, business partnership or in other cases;
• To include you in a list of prospective clients, candidates (portfolio) if you have allowed this;
• To inform you about various campaigns, products and services, job vacancies;
• To prepare statistical data on various topics of commercial interest, including job vacancies;
• In the legitimate interest

We will only process the information necessary for the purpose for which it was collected when accessing or creating a user account on the websites. THT You will always have the option to opt out of receiving marketing communications from us (and you can withdraw your consent or object at any time). We will never send you unsolicited emails, communications or share your personal information with anyone else.

There are different ways in which we may use or process your personal information. We list them below:

Consent:

If you have given your consent, we may use and process your information to provide you with the latest information regarding the offers you have requested or wish to request:

• Vehicle prospects
• Prospective customers for parts and tires
• Prospective clients for the services offered by THT (e.g. EVW)

Contractual basis:

We may use and process your personal information where necessary to enter into a contract with you and to fulfill and complete your orders, purchases and other transactions with us.

• Existing customers (contract)
• Telephone, electronic or personal communication regarding customer satisfaction index

We may use and process your personal information as set out below, where it is necessary for us to carry out activities for which it is in our legitimate business interests to do so.

• Existing customers of vehicles purchased or in the process of being purchased or simply for details about products, items or services performed by THT (e.g. EVW)
• Parts and tire customers or potential customers for and about products, items or services performed by THT (e.g. EVW)
• Existing service customers (without a contract) for technical information

Legitimate interest

If applicable, we will contact customers or referrals (those who have been active in the last two years) with sales messages regarding our latest offers or former customers in the event of a new collaboration.

Through a legitimate interest assessment we have determined that this is in the interest of all customers or partners.

We may also collect and subsequently process certain information regarding your behavior while visiting our website or using the smartphone application, in order to personalize your online experience and provide you with offers tailored to your profile. We invite you to learn more about this by consulting the section on the purposes of processing below.

On our website and smartphone application we may store and collect information in cookies and similar technologies, according to the Cookie Policy.

We do not collect or otherwise process sensitive data, which are included in the General Data Protection Regulation as special categories of personal data. We also do not wish to collect or process data from minors under the age of 16.

For Marketing we want to keep you informed about the best offers for the products/services that interest you. In this regard, we may send you any type of message (such as: e-mail / SMS / telephone / mobile push / webpush / etc.) containing general and thematic information, information on products similar or complementary to those you have purchased, information on offers or promotions, information on products of interest. In order to provide you with information of interest to you, we may use certain data regarding your purchasing behavior (e.g. products viewed / added to wishlist / purchased) to create a profile for you. We always ensure that this processing is carried out in compliance with your rights and freedoms and that decisions taken on the basis of them do not have legal effects on you and do not similarly affect you to a significant extent.

In most cases, we base our marketing communications on your prior consent. You can change your mind and withdraw your consent at any time by:

– Changing the settings in the customer account;

– Accessing the unsubscribe link displayed within the messages you receive from us; or by

– Contacting THT (ex, EVW) using the contact details described above.

In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our business. In any situation where we use information about you for our legitimate interest, we take care and take all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you can ask us at any time, by the means described above, to stop processing your personal data for marketing purposes, and we will comply with your request.

To protect our legitimate interests

There may be situations where we will use or disclose information to protect our rights and business. These may include:

– Measures to protect the website and users of THT online platforms (e.g. EVW) against cyber attacks:

– Measures to prevent and detect fraud attempts, including the transmission of information to the competent public authorities;

– Measures to manage various other risks.

The general basis for these types of processing is our legitimate interest in defending our commercial activity, it being understood that we ensure that all measures we take guarantee a balance between our interests and your fundamental rights and freedoms.

Also, in certain cases we base our processing on legal provisions such as the obligation to ensure the security of goods and valuables provided for by the applicable legislation in this matter.

How long do we keep your personal data?

As a general rule, we will store your personal data for as long as you have an account on the THT platform (e.g. EVW) or the platforms managed by us. You may at any time request that we delete certain information or close your account and we will comply with such requests, subject to the retention of certain information including after the account is closed, where applicable law or our legitimate interests require it.

To whom do we transfer your Personal Data?

We transfer information about you with THT affiliates (including TURBOS HOET, POLIMOB SRL, ICS EVW CAMIOANE SRL, TURBOS HOET ROMANIA SRL) who are subject to the same data protection standards, as well as business partners such as:

– Strategic suppliers of products and goods (DAF TRUCKS NV, PACCAR, VDL, etc.)

– IT providers

– Service providers

– Insurance companies

– Banks (Raiffeisen Bank, Unicredit Bank, Banca Transilvania, BRD)

– Auditors (MAZARS)

– Authorities (public authorities, courts, lawyers, bailiffs, investigative bodies)

How do we protect your personal data in relation to third parties who are not subject to European data protection rules?

No personal data will be transferred to third parties that do not apply personal data protection policies.

In other cases, we may transmit or provide access to certain of your personal data to the following categories of recipients:

– companies within the same group of companies as THT;

– THT (ex.EVW) Marketplace partners;

– courier service providers;

– payment/banking service providers;

– marketing/telemarketing service providers;

– market research service providers;

– other companies with whom we can develop joint programs to offer our goods and services on the market.

If we are subject to a legal obligation or if it is necessary to defend a legitimate interest, we may also disclose certain personal data to public authorities.

We ensure that access to your data by third parties, legal entities under private law, is carried out in accordance with the legal provisions regarding data protection and confidentiality of information, based on contracts concluded with them.

Which countries do we transfer to? your personal data

We currently store and process your personal data in Romania.

However, we may transfer certain of your personal data to entities located in the European Union or outside the Union, including in countries that the European Commission has not recognized as having an adequate level of protection for personal data.

We will always take steps to ensure that any international transfer of personal data is carefully managed to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, where appropriate, other safeguards, such as standard contractual clauses issued by the European Commission or certification schemes, such as the Privacy Shield for the protection of personal data transferred from within the EU to the United States.

You can contact us at any time, using the contact details set out above, to find out more information about the countries to which we transfer your data, as well as the safeguards we have put in place regarding these transfers.

How we protect the security of your personal data

We take care to protect the availability, integrity and confidentiality of your personal data. We have implemented a number of security measures to ensure the protection of your data. For example, we implement access controls, use appropriate network and system security measures such as firewalls, install patches and protect mobile devices with appropriate passwords.

We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures, according to industry standards.

The transmission of your personal data is done using encryption algorithms and we store it on secure servers, while ensuring data redundancy.

Any payment information is encrypted, using innovative, state-of-the-art technologies.

Despite the measures taken to protect your personal data, we draw your attention to the fact that the transmission of information over the Internet in general, or via other public networks, is not completely secure, and there is a risk that the data may be seen and used by unauthorized third parties. We cannot be responsible for such vulnerabilities of systems that are not under our control.

What rights do you have?

When we process your personal data, you have certain rights that you can exercise at any time. Below we provide you with an overview of these rights and what they mean for you. You can exercise your rights by contacting  dpo@thtrucks.ro

Rights that can be exercised by data subjects in relation to the processing of their personal data by TH Trucks SRL (ex. EVW HOLDING SRL):

Any data subject is guaranteed the exercise of the rights provided for by the GDPR, namely:

a) access right: data subjects can obtain from TH Trucks SRL (ex. EVW HOLDING SRL) confirmation that their data is being processed

personal data, as well as information regarding the specifics of the processing such as: purpose, categories of personal data processed, recipients of the data, the period for which the data is stored, the existence of the right to rectification, deletion or restriction of processing.

This right allows data subjects to obtain a copy of the processed personal data free of charge, as well as any additional copies for a fee;

b) the right to rectify data: data subjects may request TH Trucks SRL (ex. EVW HOLDING SRL) to modify the data

incorrect information concerning them or, as the case may be, to complete the data that is incomplete;

c) right to erasure: Data subjects may request the deletion of their personal data when:

• they are no longer necessary for the purposes for which we collected them and

we process;

• consent for the processing of personal data has been withdrawn and TH Trucks SRL (e.g. EVW HOLDING SRL) can no longer process them on other grounds;

• personal data is processed contrary to the law;

• personal data must be deleted in accordance with relevant legislation;

d) the right to withdraw consent: Data subjects may withdraw their consent to the processing of personal data processed on the basis of consent at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out prior to this moment.

e) right of opposition: data subjects may object at any time to processing for marketing purposes, as well as to processing based on the legitimate interest of TH Trucks SRL (e.g. EVW HOLDING SRL), for reasons relating to their specific situation;

f) the right to restriction of processing: Data subjects may request the restriction of the processing of their personal data if:

• contests the accuracy of the personal data, for a period that allows us to verify the accuracy of the data in question;

• the processing is unlawful and the data subject opposes the deletion of personal data, requesting instead the restriction of their use;

• the data is no longer necessary for our processing, but the data subject requests it for legal action;

• if the data subject has objected to the processing, for the period of time during which it is verified whether the legitimate rights of TH Trucks SRL (e.g. EVW HOLDING SRL) as the operator prevail over the rights of the data subject.

g) the right to data portability: data subjects may request, under the law, that TH Trucks SRL (ex. EVW HOLDING SRL)

to provide them with certain personal data in a structured, commonly used and machine-readable format. If the data subjects so request, TH Trucks SRL (ex. EVW HOLDING SRL) may transmit the said data

data to another entity, if technically possible.

h) the right to file a complaint with the National Supervisory Authority for Personal Data Processing: Data subjects have the right to file a complaint with the National Supervisory Authority for Personal Data Processing if they consider that their rights have been violated:

National Authority for the Supervision of Personal Data Processing,

B-dul G-ral. Gheorghe Magheru 28-30 Sector 1, postal code 010336 Bucharest, Romania

anspdcp@dataprotection.ro  

To exercise the rights mentioned in points a) – g) above, or for any questions about the processing of personal data carried out by TH Trucks SRL (ex. EVW HOLDING SRL), data subjects may use the contact details of the data protection officer designated by TH Trucks SRL (ex. EVW HOLDING SRL), by sending the request:

– by email to the address: dpo@thtrucks.ro  

 or

– by mail or courier to the address: str. Lunii, no. 2, loc. Gilau, Jud.Cluj for TH Trucks SRL

– phone 0372.200.000

You can access the application forms through the links below:

Access request – link

Data portability request – link

Rectification request – link

Request for restriction of processing – link

Data deletion request – link

Without prejudice to your right to contact the supervisory authority at any time, please contact us in advance, and we promise that we will make all reasonable efforts to resolve any issue amicably.

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